In United States v. Brinkley, the The Fourth Circuit held that officers, armed with an arrest warrant, lacked probable cause to enter an apartment where they had reason to believe the defendant resided. In its decision, the court noted that the courts of appeal split on the quantum of proof required for an officer to show that he or she had reasonable belief to enter a residence with an arrest warrant.

In Adams v. American Optical Corp. the Fourth Circuit held that Virginia’s two-year statute of limitations on personal injury claims barred the plaintiff-appellant’s (Adams) allegations regarding his diagnosis of coal workers’ pneumoconiosis (CWP), also known as black lung. Under Virginia law, the statute of limitations begins to run when the injury is sustained and “not when the resulting damage is discovered.” Va. Code Ann. § 8.01-230. The court found that because there was some undisputed evidence that proved to a reasonable degree of medical certainty that Adams developed CWP more than two years before filing his suit, any disputes concerning the importance of particular pieces of medical evidence were immaterial and thus, there was no genuine dispute that Adams developed CWP outside the limitations period.